Medicare Part D

Plan sponsors and their administrators, such as pharmacy benefit managers (PBMs), are increasingly imposing Direct and Indirect Remuneration (“DIR”) fees on independent pharmacies nationwide, with a focus on pharmacies in a “Preferred Cost Sharing Network” (“PCSN”). Originally intended by the Centers for Medicare and Medicaid Services as a method to “true-up” drug pricing at the point of sale, DIR fees have been utilized by PBMs to siphon money from independent pharmacies under the guise of “quality metrics.”

Join Jonathan Levitt, attorney and co-founder of healthcare law firm Frier Levitt, as he demonstrates how your pharmacy can utilize various nuanced avenues to challenge the imposition of unreasonable DIR fees against your pharmacy.

This eye-opening presentation will help you:

Understand exactly what PCSNs are and how an independent pharmacy can gain access to preferred networks

Understand the origin and scope of DIR Fees and how they are utilized in PCSNs to defray the benefits of being in a preferred network

Interpret related laws and regulations, including the Any Willing Pharmacy law and “Preferred Pharmacy Rule” and how they impact the DIR fees assessed against your pharmacy

Learn what steps your pharmacy should take to combat the imposition of unreasonable DIR fees